ID: nht69-2.12

DATE: 01/28/69

FROM: AUTHOR UNAVAILABLE; William Haddon Jr. M.D.; NHTSA

TO: House of Representatives

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your January 8 letter concerning comments by Mr. Jackson Decker of the E. D. Ptnyre Company, which was addressed to the National Highway Safety Bureau on December 20, 1968. I regret that Miss Claybrook of my staff was unable to locate Mr. Decker's letter after the call from your office requesting a copy of my response to Mr. Decker.

Mr. Decker's letter consists of comments to the Federal Highway Administration Dockets on the pending proposed regulations under which information would be supplied by manufacturers to consumers about various safety performance characteristics of motor vehicles. My staff was unaware of this letter because it was addressed to the Docket and was sent by the mail room directly to the legal office which maintains all dockets. The dockets contain much of the source material which serves as the basis for final rule making on proposed standards and regulations.

In addition, letters such as this are seldom answered not only because it is not appropriate to debate the substance of pending rulemaking actions, but also because the purpose of such correspondence is to provide information to the Government in the development of rulemaking. It is not treated as routine correspondence with the agency. In addition, the volume of such comments frequently reaches such vast proportions that it would be virtually impossible to answer them. For example, in response to a recent Federal Highway Administration proposed regulation some 4,000 comments were submitted.

Mr. Decker, incidentally, does not indicate he expected a specific answer to his letter but, rather, in his last paragraph, asks that his views "be given serious consideration before proceeding with the issuance of part 275 of the Federal Motor Vehicle Safety Standards."

On December 30, 1968, the Federal Highway Administrator issued a notice extending for 60 days the time for filing comments on a number of the proposed regulations for consumer information. This notice also specified that the proposed regulations would not apply to vehicles produced in two or more stages. I am enclosing a copy of this notice with the appropriate section marked for your information.

I regret that we had to ask you to supply a copy of Mr. Decker's letter, but I trust that the above information resolves the issues he raised.

ID: nht69-2.13

DATE: 07/17/69

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: U.S. Suzuki Motor Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of July 8, 1969, in which you ask whether a form that you enclose satisfies the requirements of Consumer Information section S75.106, Acceleration and Pusint Ability.

Your placement of the words "not capable" in the figure conforms to the requirements of the section. It is not necessary to include the words in the diagram also. In reference to your question concerning line spacing: In presenting the information "in essentially the form illustrated in Figure 1" (section 375.106(c)), it is not necessary that the manufacturer's presentation be an exact copy of the figure in respect to type face, line spacing, and so forth. The presentation in your enclosure would be adequate in those respects.

In answer to your question about teduction of the figure. The regulation did not specify a type size, but the information is required to be exactly legible. The size in which the figure appeared in the Federal Register would appear to approximate the minimum in this regard.

Finally, I should note that the "Description of Vehicles to which this Table Applies" is required by section 375.106(c)(1) to be "in the(Illegible Word) by which they are described to the public by the manufacturer". This would normally be in terms of the model designation,(Illegible Word) equipment, or other common description, not the regulatory type of "motor-driven(Illegible Word) as you indicate (unless, of course, this is your company(Illegible Word) designation of this type).

I am pleased to be of assistance.

ID: nht69-2.14

DATE: 07/18/69

FROM: AUTHOR UNAVAILABLE; Robert Brenner; NHTSA

TO: Ward School Bus Manufacturing Incorporated

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of May 28, 1969, in which you request approval of an alternative to the label locations specified in Section 367.4(c) of the Certification Regulations that will be effective as to vehicles manufactured on or after September 1, 1969.

The label location, on the panel ovay the driver's window, as shown in your enclosed photograph is acceptable.

Your cooporation is appreciated.

ID: nht69-2.15

DATE: 12/16/69

FROM: AUTHOR UNAVAILABLE; C. A. Baker; NHTSA

TO: Fiat Motor Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of November 20, 1969, to Mr. Francis Armstrong, concerning your proposed windshield wiper system.

We assume your new windshield wiping system will meet the requirements of S4.1.1.3 of Motor Vehicle Safety Standard No. 104, based upon your description of its operation. Note that S4.1.1.3 states "the highest and one lower frequency" -- the fact that you have even a lower frequency, to cycles per minute, does not conflict with this requirement. The main thing is you do offer a frequency differential of at least 15 cycles per minute measured from a low frequency of at least 20 cycles per minute.

With respect to the requirements of Standard No. 104, I must point out that this Bureau does not issue approvals of windshield wiper systems or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of the standard.

ID: nht69-2.16

DATE: 09/30/69

FROM: AUTHOR UNAVAILABLE; Robert Brenner; NHTSA

TO: Honorable John A. Blatnik

COPYEE: FHWA LEGAL 26-30; CONG. LIA.; MR. HITCKCOCK; OFF ACCIDENT AVOIDANCE, MVSPS

TITLE: FMVSS INTERPRETATION

TEXT: This is in further reply to your letter of September 9, 1969, in reference to the motor vehicle safety items discussed in Mr. Frank L. Van Alstine's letter of July 2, 1969, to Mr. H. M. Jacklin, Jr., Acting Director of our Motor Vehicle Safety Performance Service. I am enclosing a copy of our reply to Mr. Van Alstine's letter.

As we indicated in our reply, Federal Motor Vehicle Safety Standard No. 107, "Reflecting Surfaces - Passenger Cars, Multipurpose Passenger Vehicles, Trucks and Buses," affects only original installation; it does not apply to replacement windshield wiper arms, such as those referred to in Mr. Van Alstine's letter.

Federal Standard No. 210 specifies strength and general location requirements for lap and shoulder belt anchorages in passenger cars. Even though vehicles such as Mr. Van Alstine's 1969 Plymouth Valiant must meet this standard, some degree of discomfort may be experienced with certain(Illegible Word) positions and/or certain occupant sizes. As our reply stated, we are not aware of any significant injuries resulting from the present belt anchorage locations.

Based on the information supplied by Mr. Van Alstine, it does not appear that the two situations described represent violations of Federal Motor Vehicle Safety Standards.

It is most helpful to our efforts to improve highway safety when concerned citizens such as Mr. Van Alstine take the time to bring their safety experiences to our attention and that of their elected representatives.

Enclosure

ID: nht69-2.17

DATE: 10/16/69

FROM: AUTHOR UNAVAILABLE; H. M. Jacklin, Jr.; NHTSA

TO: E.T.R.T.O.

TITLE: FMVSS INTERPRETATION

TEXT: This will acknowledge your recent submittal of data to the National Highway Safety Bureau, concerning the addition of the belted-bias tire construction as a new category within Table I of Appendix A of Federal Motor Vehicle Safety Standard No. 109. Your submittal was not accompanies by a cover letter.

The National Highway Safety Bureau realizes that this construction of motor vehicle passenger car tires warrants consideration within Standard No. 109. We do not believe, however, that the introduction of additional tables to the standard is needed to cover belted-bias tires. The tables within the standard are becoming voluminous and the variety of size designations are confusing to the consumer.

During the recent ISO/TC 31 meetings in Rome, Mr. W. W. Jordan, Chief of the Tire Branch discussed briefly with members of your organization our philosophy on the standardization of the tire size designations and load inflation schedules. We have been working closely with the American Tire and Rim Association in further developing the alphanumerical system for tire size designations. We believe we are approaching a workable, standardized solution to the problem. In this light, we understand that members of E.T.R.T.O. visit the United States at regular intervals and we would like to extend an invitation to your organization to have a representative meet with us to review this matter and your petition in detail.

The National Highway Safety Bureau, at the present time, does not plan to differentiate belted-bias type tire construction from other constructions, consequently, we will delay action on your petition until we have the opportunity to discuss it with your representative.

ID: nht69-2.18

DATE: 12/01/69

FROM: AUTHOR UNAVAILABLE; Robert Brenner; NHTSA

TO: Executive Motors, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of October 28, 1969, to the National Highway Safety Bureau, concerning our Federal Motor Vehicle safety standards.

The Initial Federal Motor Vehicle Safety Standard No. 109, "New(Illegible Word) Tires - Passenger Cars" was published in the Federal Register on November 13, 1967. This standard specifies tire(Illegible Word) and laboratory test requirements for head unseating resistance, strength, endurance, and high speed performance; defines tire load ratings; and specifies labelling requirements. The standard also requested "Persons desiring an amendment to Standard No. 109 adding tires not presently listed, should submit sufficient pertinent information relative to these tires in 10 copies to the Secretary of Transportation---."

The(Illegible Word) S.p.A. of Milan, Italy requested the addition of the 165-400 tire size designation to Standard No. 109 as well as the adoption of the letter symbols(Illegible Words) for tires. The(Illegible Words) petition was approved and published in the Federal Register on April 18, 1969. The(Illegible Word) tire size designation has been listed within Table I-D of Standard No. 109 since that time.

The labelling requirements of Standard No. 109 apply to all new(Illegible Word) tires - both domestic and foreign - manufactured after January 1,(Illegible Word). There are no "special markings" required on the tires coming into this country other than those detailed in Standard No. 109. For your information, I have enclosed Federal Motor Vehicle Safety Standard No. 109 and No. 110 with amendments.

The 165-400 tire size designation is currently listed within our Standard No. 109 and the labelling requirements are considered to be reasonable and in the interest of safety. The National Highway Safety Bureau does not prohibit any tire manufacturer from fabricating motor vehicle tires. The availability of tires from a specific tire manufacturer is a matter of that company's policy for marketing and has no direct relation to Federal Motor Vehicle Safety Standard No. 109.

As required by the National Traffic and Motor Vehicle Safety Act of 1966, initial Federal Motor Vehicle Safety Standard No. 108, which deals with lighting requirements, was based on existing standards. Accordingly, the initial standard reflected existing requirements contained in Federal and State regulations and the Society of Automotive Engineers Standards on lighting equipment. Since publication of the initial standard on February 3, 1967, this Bureau has sponsored a continuing research program leading to the development of more effective and extensive requirements for vehicular lighting. In fact, during the past two years, eight research contracts have been awarded in the areas of improved forward and rear lighting systems. Under these contracts, in-depth studies, tests and evaluations will be conducted to determine the most effective color, size, intensity, location, and method of controlling the operation of the lamps which are required on the front and rear of motor vehicles. Further follow-on studies and evaluations are envisioned to determine the most-effectiveness and practicability of the proposed improved lighting systems. Results of this research will assist us in evaluating your suggestion and other similar suggestions relating to improved rear lighting systems.

ID: nht69-2.19

DATE: 12/02/69

FROM: AUTHOR UNAVAILABLE; R. H. Compton; NHTSA

TO: Thompson Aircraft Tire Corporation

TITLE: FMVSS INTERPRETATION

TEXT: In response to your letter of November 6, 1969, the Department of Transporation hereby assigns number 211 to the Thompson Aircraft Tire Corporation, South San Francisco, California, as its approved code mark. The approved code mark is for use in identifying the tire manufacturer in accordance with S4.3 of the Federal Motor Vehicle Safety Standard No. 109 and the National Traffic and Motor Vehicle Act of 1966 (15 USC 1421(1)).

You are cautioned that the approved code mark at the present time is for use only on new pneumatic passenger car tires.

ID: nht69-2.2

DATE: 05/02/69

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: Reliance Trailer and Truck Company Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 12, 1969, to the Director of the National Highway Safety Bureau concerning your questions on mounting of clearance and identification lamps on your open top bulk commodity trailers. In response to your question no. 1, identification lamps mounted below the bottom edge of the tarp as shown on your attached marked print no. 2 appear to be in compliance with Standard No. 108. With the identification lamps to mounted the rear clearance lamps may be mounted at the extreme edge of the rear lower structure as shown on print no. 2.

The answer to question numbers 2 and 3 is that the front clearance lamps should be mounted as high as practicable to clear the bottom edge of the tarp as shown on your attached marked print no. 2.

With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approvals on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of the standard.

ID: nht69-2.20

DATE: 11/24/69

FROM: R. H. COMPTON -- DIR., OFC. OF STANDARDS ON ACCIDENT AVOIDANCE, MVS PS, NHTSA; SIGNATURE BY C. A. BAKER

TO: Gumifabriken Gislaved Aktiebolag

TITLE: FMVSS INTERPRETATION

TEXT: In response to your letter of November 3, 1969, the Department of Transportation hereby assigns number 210 to the Gumifabriken Gislaved Aktiebolag, Gislaved, Sweden, as its approved code mark. The approved code mark is for use in identifying the tire manufacturer in accordance with S4.3 of Federal Motor Vehicle Safety Standard No. 109 and the National Traffic and Motor Vehicle Safety Act of 1966 (15 USC 1421 (1)).

Your attention is directed to the requirement for designation of an agent in accordance with the National Traffic and Motor Vehicle Safety Act of 1966, Subsection (110(e)). This requirement is implemented by our "General Procedural Rules, Subpart D - Service of Process; Agents.

As requested, I have enclosed a copy of the Federal Motor Vehicle Safety Standards No. 109 and No. 110 with amendments.